The Commission's marking code turns AI disclosure into a per-asset classification problem

A file carries no memory of its own history. A JPEG does not record whether it began as a photograph of a real room or as pixels from a model. The dev.to write-up's checklist splits exactly along that line: generation on one side, material manipulation of an existing image, recording or video on the other, with the emphasis on cases where a viewer could be led to believe something happened when it did not ^[5]. That is a fact about how the asset was made, and the only cheap place to record it is where the edit happened. Downstream, working from the artifact alone, you are guessing.

The trigger is publication, not use. The post reads the code as a common framework for deployers to apply when AI-generated or manipulated material is made available to others, not as a rule that flattens every internal use into the same exercise ^[6], and it contrasts a realistic altered video with brainstorming material that is never published ^[7]. That gives a scoping boundary you can implement: instrument the egress points, leave the scratch work alone.

Which makes the disclosure field, and its default, the load-bearing configuration. The post suggests defining an approval process for deciding when and how the relevant label or icon should appear ^[13]. In a content system that means a required field with at least three states, not a boolean: generated, materially manipulated, neither. A boolean defaulting to false silently asserts "not AI" across every legacy asset in the library, which is a claim nobody meant to publish. Consistency across services and platforms is what the Commission's own announcement says the framework is for ^[3], and consistency at scale is a property of defaults rather than of intentions.

For chatbots, the post argues that clear identification helps set expectations before a customer begins an interaction ^[11]. Before means the first turn or the widget frame. A line in the terms page is read, if at all, long before that moment, well after the point where it could have set any expectation.

Then the date. The post says the supplied Commission materials place applicability around the third quarter of 2026 ^[15], and it also dates the code's publication, alongside other EU activity on online safety and consumer protection, to August 2026 ^[12]. August falls inside July to September ^[14]. That puts Q3 2026 much closer than the comfortable planning horizon the framing suggests.

Treat the number the way you would treat somebody else's benchmark table. For Q3 2026 to be your program milestone, two things would have to be true: the Commission's text itself would have to state an applicability date for the code, and your specific AI Act obligations would have to attach on the same clock. Neither is established by a single secondary write-up that hedges with "around" and "the reports". The primary text, not a secondary write-up, is what should set the milestone. The classification work is worth starting on either timeline, because it is the same work whether the date is this quarter or next year.